November 29, 2018

According to railroads’ third-quarter 2018 reports released by the Federal Railroad Administration (FRA), four railroads are at risk of failing to qualify for an alternative schedule to finish implementing positive train control (PTC) by the Dec. 31, 2018 deadline.

To qualify for an extension of up to two years to finish implementing PTC, railroads must meet four criteria:

1. At least 95 percent of all PTC system hardware installed
2. Acquired all spectrum necessary for PTC, if applicable
3. Initiated sufficient revenue service demonstration (RSD)
4. Completed sufficient employee training

Based on that criteria, five railroads were still at risk of failing to qualify for an extension as of Sep. 30, 2018:

• Amtrak is now no longer at risk, having risen from 92 percent of hardware installed at the end of the third quarter to 97 percent at the end of October (it had already met the other three criteria).
• Caltrain now has 98 percent of hardware installed and has acquired all necessary spectrum, but has not initiated sufficient RSD or completed sufficient employee training.
• New Jersey Transit only has 79 percent of its hardware installed but has met the other three criteria.
• Altamont Corridor Express (ACEX) has only installed 70 percent of its hardware and has not initiated sufficient RSD, but has met the other two criteria. (ACEX tolda House subcommittee in September that the railroad was challenged by the small pool of vendors and that their status as one of the smallest railroads with PTC requirements put them “at the end of the line” to receive hardware.)
• Capital Metropolitan Transportation Authority (CMTY) has only installed 85 percent of its hardware and has not initiated sufficient RSD, but has met the other two criteria.

In addition to those, Rio Metro has received an exemption until 2020, at which time they will need to be fully PTC compliant (in other words, no additional alternative schedule after that). As of Q3 2018, the railroad has made no reported progress toward implementation, though it did receive  the largest of the FY18 Positive Train Control Grants announced in August.

ACEX and CMTY both made significant installation progress over the past quarter—CMTY, for example, went from 19 percent of locomotive hardware installed to 63 percent—but it is unclear whether that trajectory will continue to allow them to qualify by year’s end.

Four railroads that were at-risk at the end of the second quarter are now on track to be eligible for an extension: Maryland Area Regional Commuter (MARC), Trinity Railway Express, South Florida Regional Transportation Authority, and Central Florida Rail Corridor (SunRail).

Of the 40 railroads with PTC requirements, the vast majority of them will need to apply for an extension, as they meet the aforementioned criteria but do not yet have all route miles in PTC operation. Most of them have not yet submitted their safety plans, which the FRA must review before approving the extension; the agency expects an influx of these at the end of December.

Even for those railroads that are further along, interoperability—different railroads’ PTC systems communicating with one another so that a train can move between different hosts’ infrastructure while remaining in PTC operation—will be an ongoing issue. This is particularly true for Class I railroads, nearly all of which have been conditionally certified but host several other railroads on their infrastructure, and Amtrak which operates on many different hosts’ tracks (in addition to the infrastructure it owns in the Northeast and Michigan). The interoperability challenge was a main focus at the recent House hearing on PTC.